RS-13-028, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13063A265
Person / Time
Site:	Byron
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, RS-13-028
Download: ML13063A265 (11)

Text

Exelon Generation Order No. EA-12-051 RS-13-028 February 28, 2013 U.S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29,2012

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 24, 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25,2012 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2

• Reference 3 provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan complying with the guidance for the purpose of ensuring a reliable indication of the water level in associated spent fuel storage pools capable of supportIng identification of required wide range pool water level conditions by trained personnel.

U.S. Nuclear U.S. Nuclear Regulatory Commission Integrated Plan Integrated Plan Report to EA-1 2-051 EA-12-051 February 28, February 28, 2013 2013 Page 22 Page Reference 4 provided the EGC initial Reference status report regarding reliable spent initial status spent fuel fuel pool instrumentation, as instrumentation, as required required by by Reference 1. 1.

Reference 3, Appendix A-2 Reference A-2 contains contains the the specific specific reporting reporting requirements requirements forfor the the Overall Overall Integrated Plan. The Plan. The information information in the enclosure enclosure provides provides thetheByron Byron Station, Station, Units Units 11 and and22Overall Overall Integrated Plan Integrated Plan pursuant pursuant to to Appendix AppendixA-2 A-2ofofReference Reference3.3. The The enclosed enclosed Integrated Plan is based based on conceptual on conceptual design design information.

information. Final Finaldesign design details details andand associated associated procedure guidance, as as well as well as any revisions to thethe information information contained contained in in the the Enclosure, Enclosure,willwill be be provided provided inin the the 6-6-

month Integrated month Integrated Plan Plan updates required by Reference 1. 1.

This letter This letter contains contains no new regulatory regulatory commitments.

commitments. If you have any questions If you questions regarding regarding this this report, please contact David P. Helker at 610-765-5525.

report, please contact David P. Helker at 610-765-5525.

declare under penalty of perjury that the foregoing I declare foregoing is true and correct. Executed Executedon onthe 28thday the28"' day of February 2013.

Respectfully submitted, Glen T. Kaegi Director - Licensing Director Licensing & & Regulatory Regulatory Affairs Affairs Exelon Generation Company, Company, LLC LLC

Enclosure:

1.

1. Byron Byron Station, Units 1 and 22 ReliableReliable Spent SpentFuel FuelPool PoolInstrumentation Instrumentation(SFPI)

(SFPI)Overall Overall Integrated Plan Plan cc: Director, Office ofof Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Regional Administrator Administrator -- Region Region IIIIII NRC Senior Resident Resident Inspector Inspector-- Byron Byron Station, Station, Units Units 11 and and 22 NRC Project Manager, Manager, NRR NRR -- Byron Byron Station, UnitsUnits 11 and and 22 Mr.

Mr. Robert J. Fretz, Fretz, Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert Robert L.L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC NRC Illinois Emergency Management Illinois Emergency ManagementAgency Agency--Division Division of of Nuclear Nuclear Safety Safety

Enclosure Enclosure 11 Byron Station, Units 1 and 2 Byron Spent Fuel Reliable Spent Fuel Pool Pool Instrumentation Instrumentation(SFPI)

(SFPI)

Overall Integrated Plan Overall (8

(8 pages) pages)

Byron Station, Byron Station, Units Units 1 and 2 Reliable Spent Reliable Spent Fuel Pool Instrumentation Instrumentation Overall Overall Integrated Plan Applicability:

Applicability:

This integrated This integratedplan plan applies appliestoto Byron ByronStation, Station,Units Units11and and22 and and is is based on on current current conceptual design conceptual design information informationand and will willbebe revised revised as detailed detailed design design engineering engineering proceeds. Consistent proceeds. Consistent with with the the requirements requirements of of Order EA-12-051 and Order EA-12-051 and the guidance guidance in in NEI 12-02, Exelon's six-month reports will delineate progress NEI 12-02, Exelon's six-month reports will delineate progress made, any proposed made, any proposed changes in in compliance methods, updates compliance methods, updates to to the schedule and, and, ifif needed, needed, requests requests for for reliefand relief and the the basis.

basis.

General

Description:

ByronStation Byron Stationisisaa two two unit unitPressurized PressurizedWater WaterReactor ReactorStation.

Station. TheThe two two units units share share a single single Spent FuelFuel Pool Pool (SFP)

(SFP) located located in in the the Fuel Fuel Handling Handling Building Building (FHB).

(FHB). Normal Normal SFP water level is El. EI. 424'-6".

424'-6". Top ofof the spent spent fuel fuel rack rack isis El.

EI. 400'-2" 400'-2" and and toptop of of active activefuel fuel isis approximately El. EI. 398'-8".

Schedule:

The installation installation of reliable level instrumentation instrumentation for the SFP SFP associated associated with with Unit Unit 11 and and Unit 2 is scheduled scheduled for completion completion by the end of B2R18 (Fall 2014) based on the end of of the second refueling outage for Unit 2 following following submittal of this integrated plan. plan. This This isis the earlier outage sequence of of the units units discharging discharging to to the the pool.

pool.

The current milestone milestone schedule scheduleisisas asfollows:

follows:

• Complete Complete Conceptual ConceptualDesign Design(CD)(CD)forforPilot PilotPlant Plant(Limerick)

(Limerick) Complete Complete

• Complete CD CD Follow-up Walkdowns at Remaining 9 Exelon Follow-up Walkdowns Exelon Sites Sites Complete Complete

• Submit Initial 60-day Status Report Initial 60-day Report Complete Complete

• Develop Request Request forfor Proposal Proposal forfor Detailed Detailed Engineering Engineering Complete Complete Design Services Services

• • Submit Submit Integrated Integrated Plan Plan Complete with Complete with this this submittal submittal

• • Begin Detailed Detailed Engineering Engineering Design Design 1102013 Q2013

• • Procure Procure SFP SFPInstrumentation Instrumentation 202013 2Q2013

• • Complete Complete and and Issue IssueSFPI SFPIModification Modification Package Package 402013 4Q2013 11

Byron Station, Units 1 and 22 Byron Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Plan

• Begin SFPI Installation Installation 2Q2014 202014

• SFPI Installation and Put Into Complete SFPllnstaliation Into Service 4Q2014 402014 Identification of Spent Fuel Pool Identification Pool Water Water Levels:

Key spent fuel pool waterwater levels levels will will be be identified identifiedas asfollows:

follows:

Level adequate Level adequate to to support support operation operation of of the normal normal fuel fuel pool cooling cooling system system (Level 1): Indicated level 1): Indicated level on on either primary primary or or backup instrument channel of of greater greater than 19 than 19 feet feet (elevation 419'-2")above (elevation 419'-2") abovethe the top top of of the the storage storage racks racks based on on the the design accuracy design accuracy of of the instrument channel (which instrument channel (which isis to to be be determined) determined) and and aa resolution of resolution of 1 foot foot oror better ofof both the primary primary and backup backup instrument instrument channels.

channels.

This is based This based on onSpent SpentFuel FuelPoolPoolCooling CoolingPump Pumpsuction suctionstrainer elevation. A strainerelevation.

calculation demonstrating calculation demonstratingadequate adequate water water level level will willbe be performed performed as as part part of of the the detailed engineering detailed engineering design design phase phase to ensureensure thethe level level isis adequate adequatefor fornormal normal fuelfuel cooling system operation.

pool cooling operation.

Level adequate Level adequate to provide substantial radiation radiation shielding for a person person standing standing on the spent on spent fuel fuel pool pool operating operating deck deck(Level (Level 2): Indicated level 2): Indicated level on on either the primary or primary or backup backup instrument channel of of greater greater than than 10 10feet feet(elevation (elevation410"-2")

410"-2") plus plus instrumentchannel instrument channelaccuracyaccuracyabove abovethe thetoptop ofof the the storage storage racksracks based based on on specification of specification of this this level level as as adequate adequate in in NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and NEI NEI 12-02, the specified design accuracy accuracy of the instrument channel, and the relatively lowsensitivity of the instrument channel, and the relatively low sensitivity of dose rates to of to changes changesinin water waterdepthdepthatatthis thislevel.

level. ThisThismonitoring monitoring level level ensures ensures there is there is an an adequate adequatewater waterlevel leveltotoprovide providesubstantial substantial radiation radiation shielding shielding for for aa person standing on on the the spent spentfuel fuel pool pool operating operating deckdeckfrom from direct direct gamma gamma radiation radiation from from stored spent fuel.

spent fuel.

Level where fuel remains covered Level covered (Level(Level 3):3): Indicated level on either the the primary primary or backup or backup instrument instrument channelchannel of of greater greater thanthan 00foot foot(elevation (elevation 400'-2")

400'-2") plusplus instrumentchannel instrument channelaccuracy accuracyaboveabovethe thetop top ofof the the storage storage racksracks based upon upon thethe design accuracy (which (which is to be determined) determined) of of the instrument instrument channel channel for for both both the the primary and primary and backup backup instrument instrument channels.

channels. ThisThis monitoring monitoring level level assures assures that that water water isis covering the covering the stored fuelfuel seated seated in in the rack.

rack.

Instruments:

The design design of of the theinstruments instrumentswill will be beconsistent consistentwith withthetheguidelines guidelinesofofNRC NRCJLD-ISG-JLD-ISG-2012-03 and NEI 12-02. Specifically, NEI12-02. Specifically, the channels will be designed as will be as discussed discussedbelow:below:

2

Byron Station, Byron Station, Units Units 1 and and 2 Reliable Spent Reliable Spent Fuel Fuel Pool Instrumentation Overall Integrated Overall Integrated Plan Primary(fixed)

Primary (fixed)instrument instrument channel:

channel: The The primary primaryinstrument instrumentchannel channel level levelsensing sensing components components will willbebelocated locatedand and permanently permanentlymounted mountedininthe theSFP.

SFP. The The primary primary instrument channel instrument channel willwillprovide providecontinuous continuous level level indication indicationover overaa minimum minimum range range of of approximately 24 feet approximately feet 77 1/2" fromthe Y2" from the high high pool pool level elevation of of 424'-9 424'-9%2" Y2" totothethe top top of the of the spent fuel fuel racks at at elevation elevation 400'-2".

400'-2". ThisThiscontinuous continuouslevellevel indication indication will will be provided providedby byaa guided guided wavewave radar radar system, system, submersible submersible pressure pressure transducer, or or other other appropriate appropriate level level sensing technology that sensing technology will be determined that will determined during during the the detailed detailed engineering engineering design phase of the project.

phase of the project.

Backup instrument Backup instrument channel:channel: The backup instrument The backup instrument channel channel level level sensing sensing components will components willalso alsobe be located located and and permanently permanently mountedmounted in inthe the SFP.

SFP. The The backup backup instrument channel will instrument provide continuous will provide continuous level level indication indication over over aa minimum minimum range of approximately 24 feet feet 771/2" fromthe Y2" from the high high pool level elevation elevation ofof 424'-9 424'-9%2" Y2" toto the the top of the of the spent fuel fuel racks racks at at elevation elevation 400'-2".

400'-2". ThisThiscontinuous continuouslevellevelindication indication will will be provided provided by by the the same levellevel sensing sensing technology technology as asthe theprimary primary instrument instrument channel.

channel.

Reliability:

Reliability of the primary of the primary and and backup backup instrument instrument channels channels will will be assured by be assured by conformance with with the guidelines of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and NEI NEI 12-02 as discussed discussed below under Design below under Design Features Features and Program Program Features.

Features. Both Bothprimary primary and andbackup backuplevel level instrumentation channels will instrumentation channels willbebe functional functionalatatall alltimes times when when there there is is fuel fuel is is in in the the SFP with allowances for testing, with allowances for testing, maintenance or repair per NEI 12-02.

or repair per NEI 12-02. Reliability will will be be established through the use of of an augmented quality quality assurance process process (e.g.,

(e.g., aaprocess process similar to that applied applied to to the the site sitefire fire protection protectionprogram).

program).

Design Features Features Instrument Instrument Channel Channel Design:

Design: Instrument channel design will be be consistent consistent with with the the guidance guidance of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and and NEINEI 12-02.

12-02.

Arrangement:

Arrangement: The The current current plan plan is is to to install install SFP SFP level level sensors sensorsinin the thenorthwest northwestand and southwest corners of southwest corners of the the SFP SFP separated separated by by a distance distance inin excess excess of 20 feet.

of 20 feet. The The sensors sensorsthemselves themselveswill will be bemounted, mounted,to tothe theextent extentpractical, practical, near nearthethepool poolwalls wallsand and below below the poolpool curb curb toto minimize minimize their exposure to to damaging damaging debris debris and andnotnotinterfere interfere with with SFP activities.

activities. Instrument Instrument channelchannel electronics electronics and and power power supplies supplies will will bebe located in located in seismic seismic and and missile missile protected protected areasareaseither eitherbelow belowthe theSFPSFPoperating operatingfloor floor or in buildings other than or in buildings other than the FHB. The areas to be selected will provide suitable FHB. The areas to be selected will provide suitable radiation radiation shielding shielding andandenvironmental environmentalconditions conditionsfor forthe theequipment equipmentconsistent consistentwith with 33

Byron Station, Byron Station, Units 1 and 2 Reliable Spent Fuel Pool Reliable Pool Instrumentation Instrumentation Overall Integrated Plan manufacturer's recommendations.

instrument manufacturer's recommendations. Equipment Equipment and and cabling cabling for for power power supplies and indication for each indication for each channel will be separated will be separated equivalent equivalent to to that provided provided for redundant for redundant safety related services.

Mounting: Design Design ofof the the mounting mountingofofthe the sensors sensors in in the SFP shall shall bebe consistent consistent with the with the seismic Class II criteria.

criteria. Installed Installedequipment equipmentwill will be be verified verified toto be be seismically seismically adequate for adequate for the the seismic seismic motions motions associated associated with with the themaximum maximum seismic seismicground ground motion considered motion considered in the design of of the plant plant area areain in which which itit is installed.

Qualification: Reliability Reliability of of both instrument channels both instrument channels will demonstrated via an will be demonstrated combination of design, analyses, operating experience, appropriate combination experience, and/orand/or testing testing of of channel components for the following sets of parameters:

• conditionsinin the conditions the area of of instrument instrument channel channel component component used for for all all instrument components,

• effects of effects of shock shock and and vibration vibration on on instrument instrument channel channel components components used used during and following during following anyany applicable applicable event, and and

• seismic effects on instrument channel components used used during during andand following following a potential seismic event.event.

Temperature, Temperature, humidityhumidity and and radiation levels consistent with radiation levels with the the conditions conditions in in the the vicinity vicinity ofofthe theSFPSFP and and the the area of use use considering considering normalnormal operation, operation, eventevent andandpost-post-event conditions conditions for for no fewer fewer than seven seven daysdayspost-event post-eventororuntiluntiloff-site off-site resources resources can bebe deployed deployedby bythe themitigating mitigatingstrategies strategiesresulting resultingfrom fromOrder OrderEA-12-049 EA-12-049will will be be addressed in the detailed design engineering in the detailed design engineering phase of the project. Examples of the project. Examples of of post-event (beyond-design-basis)

(beyond-design-basis) conditions conditions to be be considered considered are:are:

• radiological conditions for radiological conditions for aa normal refueling refueling quantity of freshlyfreshly discharged discharged (100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuelfuel with with SSFP FP water level 3 as as described describedininOrder OrderEA-12-051, EA-12-051 ,

• temperature temperature of of 212 212 degrees degreesFFand and100%

1000/0relative relativehumidity humidityenvironment, environment,

• boiling water and/or boiling water and/or steam steam environment, environment,

• a concentrated borated borated water water environment, environment, and

• the impact impact ofof FLEX FLEX mitigating strategies.

mitigating strategies.

4

Byron Station, Byron Station, Units Units 1 and 2 Reliable Reliable Spent Spent Fuel Pool Instrumentation Instrumentation Overall Overall Integrated Plan Components of Components of the instrument instrument channels channels will will be be qualified qualified for for shock shock and andvibration vibration using one or more of the following using methods:

following methods:

• components are components are supplied supplied by by manufacturers manufacturers using using commercial commercial quality quality programs (such programs (such as as IS09001, 1509001, "Quality "Quality management management systems systems -

Requirements") with shock shock and vibrationvibration requirements requirements includedincluded in in the the purchase specification purchase specification at at levels levels commensurate commensurate with with portable portable hand-held hand-held device or transportation applications; applications;

• components have havesubstantial substantialhistory historyofofoperational operationalreliability reliability inin environments environments with significant shock and vibration loadings, such as portable hand-held with significant shock and vibration loadings, such as portable hand-held devices or transportation applications; or or

• components are inherently resistant to shock shock and and vibration vibration loadings, loadings, suchsuch as as cables.

effects on For seismic effects on instrument instrument channel channel components used used after after aa potential potential seismic seismic event for event for only only installed installed components components (with the exception (with the exception of of battery battery chargers chargers and and replaceable batteries), the the following measures will following measures will be used used toto verify verify that that the the design design and installation installation isis adequate. Applicable components are rated by Applicable components by the the manufacturer manufacturer (or (or otherwise tested) for otherwise tested) for seismic seismic effects effects at levels levels commensurate commensurate with with those those of of postulated postulated designdesign basisbasis eventevent conditions conditions in in the the areaareaofofinstrument instrumentchannel channel component component use useusing usingone oneorormoremoreofofthe thefollowing following methods:

methods:

• instrument instrument channelchannel components components use known known operating operating principles principles and are are supplied supplied by manufacturers manufacturers with with commercial commercial quality quality programs programs (such (such as as IS09001). The Theprocurement procurementspecification specification and/or and/orinstrument instrument channel channel design design shall include the seismic seismic requirements requirements and and specify specify thetheneed needfor forcommercial commercial design design andand testing testing underunder seismic seismic loadings loadings consistent consistent with with design design basis basis values values atat the theinstalled installedlocations; locations;

• substantial history history of of operational operationalreliability reliability inin environments environmentswith withsignificant significant vibration, vibration, such such as asfor forportable portablehand-held hand-helddevices devicesoror transportation transportation applications.

applications. Such Such aa vibration vibration design design envelope envelope shall shall bebe inclusive inclusive of of the the effects effects ofof seismic seismic motionmotion imparted imparted to to the the components components proposedproposed at at the the location location ofof the the proposed proposedinstallation; installation;

• • adequacy adequacy of of seismic seismic design design and and installation installation is is demonstrated demonstrated based based on onthe the guidance guidance in in Sections Sections7,7,8,8,9, 9, andand1010ofofIEEE IEEEStandard Standard344-2004, 344-2004,"IEEE "IEEE 55

Byron Station, Units 1 and 2 Byron Reliable Reliable Spent Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Plan Recommended Practice Practice for for Seismic SeismicQualification Qualification of of Class Class11EE Equipment Equipmentfor for Nuclear Nuclear Power Generating Stations",

Power Generating Stations" orI or aasubstantially substantially similar similar industrial industrial standard;

• demonstration demonstration that that proposed proposed devices devices are substantially similar are substantially similar in design to in design to models models thatthat have been previously previously testedtested for seismic effectseffects in excess of the plant design plant design basis basis at thethe location where the instrument location where instrument is to be be installed installed (g-(g-and frequency ranges);

levels and ranges); or

• seismic qualification using seismic qualification using seismic motion consistent seismic motion consistent with with that of of existing existing design basis basis loading loading atatthe theinstallation installation location.

location.

Independence: The primary primary instrument instrument channel will will be be independent of of the the backup backup instrument channel.

instrument channel. This independence will This independence will be achieved achieved through through physical physical and and electrical electrical separation separation of of each channels' components components commensurate commensuratewith with hazard hazard andand electrical electrical isolation isolation needs.

needs.

Power Supplies: Each channel will will be normally normally powered powered fromfrom aadifferent different 120Vac 120Vac bus. UponUpon loss of of normal normal ac acpower, power,individual individual channel channelinstalled installed batteries batterieswill will automatically maintain continuous channel maintain continuous channel operation.

operation. The batteries will The batteries be will be replaceable replaceable and be be sized sized to tomaintain maintain channel channel operation operation until until off-site off-site resources can can be deployed by be deployed by thethemitigating mitigating strategies strategiesresulting resulting fromfromOrderOrderEA-12-049.

EA-12-049.

Additionally, each Additionally, each channel will have channel will provisions for have provisions for connection connection to another another suitable suitable power source.

Accuracy: The The instrument instrument channels channels will will be designed to be designed to maintain maintain theirtheir design design accuracy accuracy following followingaa powerpower interruption interruption or or change change in in power power source source without without recalibration. Instrument recalibration. Instrument channel accuracy, accuracy, to to be be determined determined during during detailed detailed design, design, will consider will consider Spent Spent FuelFuel Pool Pool conditions conditions (e.g.,(e.g., saturated water, water, steam steam environment, environment, concentrated borated water), as well as, other applicable applicable radiological radiological and environmental conditions and environmental conditions and include include display display accuracy.

accuracy. Instrument channel Instrument channel accuracy will be sufficient will be sufficient toto allow allow trained trained personnel personnel to to determine when when the the actual actual level exceeds the level the specified specified lower lower levellevel ofof each indicating indicating range (levels (levels 1, 1, 22 or or3)3) without conflicting conflicting oror ambiguous ambiguous indications.

indications.

Testing: Instrument Instrument channel design design will will provide for routine routine testing and and calibration calibration consistent with with the guidelines guidelines of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and NEI NEI 12-02.

12-02. Details Detailswill will determined during be determined during detailed designdesign engineering.

engineering.

6

Byron Station, Byron Station, Units 1 and 2 Reliable Spent Reliable Spent Fuel Pool Instrumentation Instrumentation Overall Overall Integrated Plan Display: The Display: primary and The primary and backup instrument displays will will be be located located at the control control room, room, alternate alternate shutdown shutdownpanel, panel, oror other other appropriate appropriateand and accessible accessible location.

location. The specific location specific location willwillbe be determined determined during during detailed detailed design.

design. An An appropriate appropriate and accessible location accessible location willwill include the following following characteristics:

• occupied occupied or promptly accessible or promptly accessible to the appropriate to the appropriate plant plant staff staff giving giving appropriate consideration to various various drain drain down down scenarios, scenarios,

• + outside the outside the area surrounding surrounding the the SFP SFP floor floor (e.g.,

(e.g., an an appropriate appropriate distance distance from from the radiological sources the radiological sources resulting from an resulting from impacting the Spent an event impacting Spent Fuel Pool),

• + inside a structure providing protection against adverse weather, and inside

• outside of of any any very very high high radiation radiationareas areasororLOCKED LOCKEDHIGH HIGHRAD RADAREAAREAduring during normal operation.

Program Features Program Training: Personnel performing functions Personnel performing functions associated associated with with these these Spent Fuel Fuel Pool Pool level level instrumentation instrumentation channels channels willwill be trained to to perform perform the the jobjobspecific specificfunctions functions necessary necessary for for their assigned assigned taskstasks (maintenance, (maintenance,calibration, calibration, surveillance, surveillance, etc.). This This training will be consistent consistent with with equipment equipment vendorvendor guidelines, guidelines, instructions instructions and and recommendations. The The Systematic Systematic Approach Approach to Training Training (SAT) (SAT) will will be used to be used to identify the identify the population population to to be trained and be trained and totodetermine determinethe theinitial initialand andcontinuing continuing elements of of the the required required training.

training. Training Training willwill be completed prior be completed prior to placing placing the the instrumentation in service.

in service.

Procedures: Procedures Procedures will will be developed using using guidelines guidelines and and vendor vendorinstructions instructions address the to address the maintenance, maintenance, operationoperation and and abnormal abnormal response response issues issuesassociated associated with the primary with primary andand backup channels channels of of Spent SpentFuel FuelPoolPoolinstrumentation.

instrumentation.

Procedures Procedureswill will also address addressthe thefollowing following situations:

situations:

• If, If, at the the time time of of ananevent eventororthereafter thereafteruntil until the the unit unit isisreturned returned totonormal normal service, an instrument instrument channel channel ceases ceases totofunction, function, its its function function will will be be recovered within within a period period of of time time consistent consistent with with the the emergency emergencyconditions conditions that that may may exist exist atat the the time.

time.

• If, If, at at the the time time of of ananevent eventororthereafter thereafteruntiluntil the the unit unit isisreturned returned totonormal normal instrument channel component service, an instrument component must must be be replaced, replaced, itit maymay bebe 77

Byron Station, Units 1 and 22 Byron Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan with a commercially replaced with commercially available available component component that that mayor may or may not meet all of the qualifications of the qualifications noted noted above above to tomaintain maintain instrument instrument channel channel functionality.

Testing and Calibration: The testing and and Calibration: and calibration calibration of of the the instrumentation instrumentation will will be consistent with with vendor recommendations or or other other documented documented basis. basis.Calibration Calibrationwill will be specific to the be specific the mounted mounted instruments instruments andand the the displays.

displays. Calibration will be performed performed to to an Instrument Instrument Maintenance Maintenance Procedure (BIP/BISR (BIP/BISR series). A Passport series). A Passport PMID will PMID willbe beused used to to direct direct frequency frequency for performance performance of of the the instrument instrumentcalibration.

calibration.

Need Basis: Exelon Relief and Basis:

Need for Relief Exelon is requesting relief is not requesting relief from from thethe requirements requirements of of Order EA-12-051 EA-12-051 or the guidance guidance in in NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 at at this this time.

time.

Consistent with with the requirements requirements of of Order Order EA-12-051 EA-12-051 and the the guidance guidanceininNEI NEI12-02, 12-02, Exelon's Exelon's six-month six-month reports reports will willdelineate delineateprogress progressmade,made, any proposed changes any proposed changes in in compliance compliance methods, methods, updates updates to to the schedule, and if the schedule, if needed, needed, requests requests forfor relief relief and and their basis.

References:

1) NRC NRC OrderOrder Number Number EA-12-051, EA-12-051, Order Order Modifying Modifying Licenses Licenses with Regard to with Regard to Reliable Reliable Spent Spent Fuel Pool Instrumentation, dated March 12, 12,2012 2012 NRC Interim

2) NRC Interim Staff Staff Guidance JLD-ISG-2012-03, JLD*ISG-2012-03, Compliance Compliance with with Order Order EA EA 051, Order Modifying Licenses Order Modifying LicenseswithwithRegard Regardto Reliable Spent to Reliable Fuel Pool Spent Fuel Pool Instrumentation, Revision 0, Instrumentation, Revision 0, dated August 29, 2012 2012

3) NEI NEI 12-02, 12-02, Industry Guidance for for Compliance Compliance with with NRC NRC OrderOrder EA-12-051, EA-12-051, "To "To Modify ModifyLicenses Licenses with with Regard Reliable Spent Regard to Reliable Spent Fuel FuelPoolPoolInstrumentation",

Instrumentation" I Revision Revision 1, 1, dated August August 24, 2012 2012

4) NRC NRC OrderOrder Number Number EA-12-049, EA-12-049, Order Order Modifying Modifying Licenses Licenses withwith Regard Regard to to Requirements for Requirements for Mitigating Strategies for Mitigating Strategies for Beyond-Design-Basis Beyond-Design-Basis External External Events, Events, dated March 12, 2012 March 12, NEI 12-06,

5) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012 Guide, Revision

6) IEEE IEEE Standard 344-2004, IEEE IEEE Recommended Practicefor Recommended Practice for Seismic SeismicQualification Qualification of Class Class 11E Equipment for for Nuclear Nuclear Power Generating Stations 8